We express major concerns with the reduced housing requirement outlined in the updated submission plan. The plan now identifies a minimum of 14,688 new homes to be delivered between 2021 to 2038, which equates to 816 dwellings per annum. This represents a 14% decrease from the previously proposed 945 dwelling per annum figure, which represented an ambitious, yet realistic, economic growth led figure. This change has arisen from the Council?s decision to now just pursue the local housing need figure generated by the Governments standard housing method, namely 816 dpa. Paragraph 61 of the 2021 NPPF is clear that the local housing need figure represents the minimum number of homes needed. The decision to add no uplift to the minimum housing need figure, which fails to take into account economic growth factors, therefore represents a do minimum approach and will result in Warrington being unable to reach its full potential with a housing requirement that is aligned with its economic growth aspirations. Our primary concerns with the reduced housing requirement is that it will exacerbate existing affordability issues, with Warrington's Affordability Ratio having worsened over the last 20 years, and will fail to build on Warrington?s strong economic growth in recent years. This is particularly important in the Warrington context given that the Borough has seen strong employment growth in recent years. We also have concerns with the land supply figures suggested by the Council, and consider there to be a need for additional Green Belt land to accommodate in excess of 4,000 + dwellings in order for the Council to meet their housing needs.

The large housing requirement to be delivered across the plan period points towards a need for a dispersed approach to growth across the Borough, including towards small rural villages like Broomedge which have a capacity to deliver modest and sustainable level of growth. we consider the Council have largely ignored the rural settlements located within the Borough. We accept such settlements will not accommodate significant levels of development. However, it is equally vital that rural communities contribute to the objectives of sustainable development. Indeed, the lack of any growth will lead to stagnation and ultimately loss of services and would therefore run counter to the objectives of the NPPF. We continue to highlight the case for sustainable levels of growth in rural settlements such as Broomedge, which Mr and Mrs Martin?s land parcel could suitably accommodate. We believe there are strong arguments and facts that would lead to Broomedge being identified as a village settlement that can be omitted from the Green Belt (with the precise boundaries to be defined) and that some moderate additional growth would help meet local needs and support/sustain existing services within the local community. The Council will recall our previous call for site submission in relation to Mr and Mrs Martin?s land parcel put forward for residential development. The land parcel has capacity to accommodate modest and sustainable levels of residential growth, which could assist in meeting local housing needs in Broomedge in a suitable and sustainable manner.

The Council?s Green Belt evidence base still fails to consider whether villages lying in the Green Belt should continue to be ?washed? over by the Green Belt, or whether there is scope for the settlement boundary to not be ?washed? over and the green belt designation to surround just the village boundary instead. This is a fundamental concern that needs rectifying, being an issue that has prevailed despite the Local Plan now being at an advanced stage and scheduled for submission for Examination in Public next year. There is now a need to assess the contribution villages such as Broomedge make to the openness of the Green Belt, to ensure compliance with NPPF paragraph 144 (previously 86) which represents a material change to the policy context when Warrington last assessed ?washed over? Green Belt villages. The upshot of paragraph 144 is that if a village?s character makes an important contribution to the essential characteristic of the Green Belt (i.e. its openness), then there is justification to maintain the village in the Green Belt. However, if there are areas within the village that are not open in character, or the village as a whole does not make an important contribution to the openness, retaining the village in the Green Belt, either through the washing over or ?infilling? of the village, would be entirely at odds with paragraph 144. Indeed, this would also be at odds with paragraph 143, which confirms local authorities should ?not include land which it is unnecessary to keep permanently open? when defining Green Belt boundaries. It is also at odds with the NPPF policies which support a thriving rural economy and the ability for villages to support sustainable development (paragraph 79). In carrying out this fundamental additional work, we believe there are strong arguments and facts that would lead to Broomedge being identified as a village settlement that can be omitted from the Green Belt (with the precise boundaries to be defined) and that some moderate additional growth would help meet local needs and support/sustain existing services within the local community.